UPDATE DECEMBER 2022: We did it – energy from burning native forest biomass no longer counts as "renewable"!

As this regulatory change has been made, we are publishing our submission here, even though the committee has not yet done so.

Download this submission on the Native forest biomass in the Renewable Energy Target: consultation paper (PDF 250 KB).

The Department of Climate Change, Energy, the Environment and Water recently sought comments on whether native forest biomass should be counted as "renewable" for the purpose of the Renewable Energy Target.

It should not.

Below are some of the major points from our submission, which might one day be published on the department's website.

Biomass is a fossil fuel that didn't have time to turn into coal

RET-eligible activities are activities that aim to reduce net greenhouse gas concentrations by either:

  • sequestering carbon dioxide; or
  • reducing net emissions

In contrast, burning of native forest biomass releases carbon dioxide with a promise of recapturing it over decades. There is no overall decrease in greenhouse gas emissions or concentrations. Classifying biomass as a "renewable" energy source is therefore specious.

The cycle is not even particularly fast. Emissions from burning biomass are instantaneous; it takes many decades to remove this carbon from the atmosphere through forest regrowth. We rightly recognise that coal and gas are not renewable even though they will be recreated over millions of years.

Burning wood is even worse in some ways – it releases more carbon dioxide than coal to produce the same amount of electricity.

Logging native forests causes poor ecological, environmental and health outcomes

Our native forests are being degraded rapidly, endangering the biodiversity that depends on these habitats. Destroying these forests leads to extinction of species.

Biomass energy projects might claim to use "residue" biomass, but there is no such thing. The forest mass referred to as "residue" is integral to the ecosystem health of the forest.

Studies also point to the increased risk of severe bushfires in regrowth, as opposed to mature forests. This is thought to be caused by reduced ability to retain moisture once the canopy is disturbed, and regrowth increasing the fuel load closer to the ground. Mature trees are also more likely to survive a bushfire.

Mature forests are vital for the health of water catchments so their detriment is the detriment of harvested water.


Burning forests accelerates climate breakdown, harms forest ecosystem integrity, and has other environmental and social risks.

However we look at it, using forest biomass for industrial scale bioenergy is worse than the alternatives and should end worldwide.

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